Louise O'Toole

Expertise

Louise provides a mixture of traditional private client and UK tax advice for both international and domestic clients, in particular to mid- and high-net-worth individuals either living in the UK or non-UK individuals with UK interests. Her most common areas of advice include:

• Tax planning for clients who are moving to or leaving the UK, to minimise their UK tax exposure.
• Determining an individual’s UK residence and domicile status under UK law and explaining the impact this has for UK tax purposes.
• Establishing and assisting with the administration of UK charities and/ or UK trusts.
• Using (and reviewing) non-UK structures to hold personal wealth. 
• Advising on UK succession laws and how conflicts with non-UK succession laws can be resolved.
• Assisting with UK inheritance tax planning and the implementation work which flows from this.
• Assisting with the preparation of a wide range of documents, including wills, powers of attorney and supplementary trust documents.
• The administration of estates, often involving a cross-border element and/ or other complexities. 
   

Experience

1. Advising a wide range of high-net-worth Middle Eastern clients on the UK tax implications of their non-UK structures (particularly where UK real estate is owned via a non-UK company/ trust), the preparation of UK wills and how they may be able to mitigate their UK inheritance tax exposure.
2. Dealing with the administration of a complex and high-value cross-border estate involving UK real estate, non-UK structures and associated loans, all of which have been brought within the scope of UK inheritance tax as a result of the changes which took place in 2017. Presenting our review of complex inheritance tax legislation in a clear manner, aiming for the best result for the client.
3. Assisting a high-net-worth individual with his relocation to the UK (having also dealt with the high-value estate of his late mother, which spanned across the UK and several EU jurisdictions). Advising on the succession law applicable to the client’s worldwide estate, the application of UK tax laws to UK tax resident but non-UK domiciled individuals, the concept of central management and control, the taxation of employment income whilst UK tax resident, the remittance basis of taxation, the purchase of a UK property and clean capital planning.
4. Dealing with the set-up of a charitable family trust to assist with the advancement of education in the UK. Registering said trust successfully with the UK charity commission and also with HMRC for gift-aid purposes. Assisting with the ongoing administration of said charity and ensuring that compliance requirements are met going forwards.
5. Assisting high-net-worth domestic clients with their will preparation, inheritance tax planning, lasting power of attorney preparation and registration and the assignment of their life assurance policies to a newly created life assurance trust. Advising on the potential for the creation of a lifetime trust to assist with the future education of their grandchildren and/ or making regular gifts out of income.